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MONTHYEARML18333A1092018-11-28028 November 2018 Presentation Slides for Diablo Public Meeting to Discuss Proposed Exemption Request for Decommissioning Funds Project stage: Meeting ML18348A4202018-12-31031 December 2018 Summary of Meeting with Pacific Gas & Electric Co. to Discuss Exemption Request to Withdraw Funds from the Nuclear Decommissioning Trusts to Fund Decommissioning Planning Activities at Diablo Canyon Nuclear Power Plant Project stage: Meeting 2018-11-28
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Category:Meeting Briefing Package/Handouts
MONTHYEARML24036A3382024-02-0505 February 2024 Environmental Scoping Meeting for the Diablo Canyon License Renewal Application - February 8 Meeting Slides ML24030A4672024-01-30030 January 2024 Environmental Scoping Meeting for the Diablo Canyon License Renewal Application - February 1 Meeting Slides ML23249A1592023-09-13013 September 2023 License Renewal Application Pre-Application Meeting: September 13, 2023 ML23255A0012023-09-13013 September 2023 PG&E Slides for 9/13 Public Meeting Related to Diablo Canyon License Renewal ML23174A0562023-06-26026 June 2023 Slides for TSTF-505 Pre-Submittal Public Teleconference 6-26-2023 ML23143A0882023-05-24024 May 2023 May 24, 2023, Public Meeting Slides Related to Diablo Canyon License Renewal ML23118A0902023-05-0303 May 2023 May 3, 2023, Diablo Public Meeting Slides ML23143A0952023-05-0303 May 2023 May 3, 2023, Diablo Public Meeting Slides for PG&E Presentation ML23079A0452023-03-16016 March 2023 RIC 2023 Slides - Maureen Zawalick TH19 ML22339A1022022-12-0505 December 2022 Pg_E Presentation for NRC Public Meeting ML22200A0712022-07-21021 July 2022 Post-Shutdown Decommissioning Activities Report Public Meeting Slides - July 21, 2022 ML22200A0722022-07-21021 July 2022 PG&E Slides for Post-Shutdown Decommissioning Activities Report Public Meeting, Site-Specific Decommissioning Cost Estimate, and Irradiated Fuel Management Plan - July 21, 2022 ML21223A0842021-08-11011 August 2021 Slides for Post Shutdown EP pre-submittal Public Teleconference 8-30-2021 ML21060B1872020-01-26026 January 2020 Enclosure 3 - 1-26-21 Diablo Canyon Renewal pre-app Meeting Slides ML19165A0092019-06-14014 June 2019 Pre-Submittal Meeting - Presentation Slides ML18333A1092018-11-28028 November 2018 Presentation Slides for Diablo Public Meeting to Discuss Proposed Exemption Request for Decommissioning Funds ML17296A2222017-08-29029 August 2017 Presentation on Reactor Decommissioning for the August 29, 2017 at Congressman Salud Carbajal'S Public Meeting at San Luis Obispo Near Diablo Canyon ML15232A0102015-08-0404 August 2015 Diablo Canyon Power Plant - Risk-Informed Technical Specification Completion Times (TSTF-505) License Amendment Request: August 4, 2015 ML15216A4112015-08-0404 August 2015 TSTF-505: August 4, 2015 Public Meeting ML15216A4082015-08-0404 August 2015 Diablo Canyon Power Plant - Risk-Informed Technical Specification Completion Times (TSTF-505) License Amendment Request: August 4, 2015 ML15209A9442015-07-28028 July 2015 June 24, 2015, Summary of Annual Assessment Meeting with Pacific Gas and Electric and Public Open House Regarding Diablo Canyon Power Plant 2014 Performance ML15202A0982015-07-21021 July 2015 Slides for the August 5, 2015 Diablo Canyon Power Plant License Renewal Application Public Scoping Meeting ML15117A0692015-04-28028 April 2015 Pacific Gas and Electric Co. April 28, 2015, Public Meeting Slides for Diablo Canyon Seismic Hazard Reevaluation ML15117A2262015-04-28028 April 2015 Nuclear Regulatory Commission April 28, 2015, Public Meeting Slides for Diablo Canyon Seismic Hazard Reevaluation ML15035A0062015-02-0404 February 2015 Meeting Presentation, Diablo Canyon Power Plant Process Protection System Replacement Lessons Learned Using ISG 6 NRC Meeting on Digital I&C. ML15029A0942015-02-0303 February 2015 Alternate Source Term Pre- Submittal Meeting on February 3, 2015 (TAC Nos. MF5596 and MF5597). AST LAR NRC Meeting Presentation ML15014A2232015-01-14014 January 2015 Slides Regulatory Conference - January 14, 2015 ML14188A9702014-07-0808 July 2014 14-07-08 ISG-06 Experience Presentation July 8 2014 Digital IC Meeting ML14155A3742014-06-0404 June 2014 May 22, 2014, Summary of Annual Assessment Meeting with Pacific Gas and Electric Regarding Diablo Canyon Power Plant 2013 Performance ML14077A2872014-03-18018 March 2014 Transcript of the 612th ACRS Meeting, March 6, 2014 (Open) Pages 1-317 ML13150A1712013-11-19019 November 2013 1978 - Rhrp Cavitation ML13274A5142013-10-0202 October 2013 License Slides, 10/2/13 Pre-Application Meeting with Pacific Gas and Electric Company to Discuss Upcoming Structural Weld Overlay Relief Request to Use an Alternative to Disposition Detected Laminar Indications at Diablo Canyon, Unit 2 (TAC ML13269A0052013-09-26026 September 2013 Licensee Slides for 9/26/13 Meeting to Discuss Amendment Request to Adopt Technical Specifications Task Force TSTF-505, Provide Risk-Informed Extended Completion Times, RITSTF Initiative 4B ML13268A0022013-09-25025 September 2013 Slide Presentation for 9/25/13 Preapplication Meeting - Use of Leak-before-break for Fuel Structural Analyses and Coolable Geometry ML13268A0052013-09-24024 September 2013 Slide Presentation for 9/24/13 Pre-application Meeting, Diesel Generator License Amendment Request ML13159A0092013-06-0404 June 2013 Notable Failures in Nondustructive Testing - June 4, 2013 Public Meeting ML13066A7402013-03-0707 March 2013 Licensee Slides from 3/7/13 Pre-Application Meeting with Pacific Gas and Electric Company(Tac MF0687 & MF0688) ML13044A7352013-02-12012 February 2013 Licensee Slides from 2/12/13 Public Meeting to Discuss License Amendment Requests for Degraded Voltage Protection and Control Room Dose Analysis of Record at Diablo Canyon, Units 1 and 2 ML13024A4052013-01-24024 January 2013 Licensee Slides from 1/24/13 Meeting to Discuss Offsite Power ML13018A1342013-01-15015 January 2013 Pacific Gas and Electric Handouts from January 15, 2013 Meeting Regarding Pending License Amendment Request Related to Diesel Generator Technical Specifications ML12355A1612012-12-18018 December 2012 PG&E Handouts from the December 18, 2012, Meeting with the NRC Related to Emergency Core Cooling System Evaluations (TAC Nos. MF0313 and MF0315) ML12347A3102012-12-12012 December 2012 Summary of Meeting with Public on Diablo Canyon Power Plant ML12311A0492012-09-18018 September 2012 Part 26 Public Meeting NEI Presentation Slides ML12226A2552012-08-0707 August 2012 License Slides from 8/7/12 Meeting with Pacific Gas and Electric Regarding Future License Amendment Associated with Diesel Generator Technical Specifications ML12193A1412012-07-25025 July 2012 6/28/2012 Summary of Meeting with Pacific Gas and Electric to Discuss Digital Replacement of Process Protection System at Diablo Canyon, Units 1 and 2 and Presubmittal of TSTF-493 Option B License Amendment Request (TAC ME7522-ME7523, ME851 ML12157A2722012-06-11011 June 2012 5/31/2012 Summary of Telephone Conference with Licensees Regarding Near Term Task Force Recommendation 2.1 Seismic Reevaluations - Diablo Canyon, 1 and 2, San Onofre, Units 2 and 3, Columbia Generating Station, and Palo Verde, Units 1, 2, a ML1202500572012-01-18018 January 2012 Meeting Slides Process Protection System Replacement LAR Acceptance Review Meeting Presentation ML1202500792012-01-18018 January 2012 Project Plan for Diablo Canyon Digital Upgrade of Process Protection System LAR Review ML1117205702011-06-20020 June 2011 Licensee Slides from 6/20/11 Pre-Licensing Meeting on Seismic License Amendment Request ML1116405342011-06-0707 June 2011 Slides from Meeting with Pacific Gas and Electric Company Regarding Diablo Canyon Process Protection System Replacement 2024-02-05
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Diablo Canyon Power Plant Decommissioning Exemption Request Pre-Submittal Meeting November 29, 2018 1
Pacific Gas and Electric Participants
- Brian Ketelsen - Diablo Canyon Power Plant (DCPP)
Decommissioning Project Controls Manager
- Jennifer Post - Pacific Gas and Electric Company (PG&E) Chief Counsel for DCPP
- Philippe Soenen -DCPP Decommissioning Environmental and Licensing Manager 2
Agenda
- Submittal Overview .... 8
Introduction
- PG&E currently plans to operate DCPP Units 1 and 2 until expiration of the current operating licenses in November 2024 and August 2025, respectively
- PG&E forecasts to submit the Certification of Permanent Cessation of Power Operations on November 27, 2018
- This early decision to retire DCPP provides PG&E a unique opportunity - a lead time of 6 years to plan for decommissioning
- PG&E Has Developed A Site-Specific Decommissioning Cost Estimate (DCE). The DCE demonstrates:
- Executing planning activities before permanent shut down would allow physical decommissioning to begin shortly after permanent shut down (cost estimate ~$187.8M ($2017))
- Early planning would reduce the duration and cost of decommissioning (cost savings ~$166.1M ($2017)) 4
Introduction DCPP Nuclear Decommissioning Trusts (NDTs)
- DCPP NDTs have been funded as directed by the California Public Utilities Commission (CPUC) and in full compliance with NRC requirements
- Funds cover all types of decommissioning costs:
- The total balance of the customer-funded DCPP NDTs as of December 2017 is $3.17B.
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Introduction NRC Regulations for Decommissioning Trust Uses
- Without an exemption, prior to permanent cessation of operations, use of NDT funds for decommissioning planning is restricted to 3% of the generic minimum decommissioning amount
- Equates to $37.2M total for DCPP Units 1 and 2
- The 3% cannot be used for spent fuel management or site restoration planning absent:
(1) a clear indication that monies in the fund were collected for those purposes and are clearly and consistently accounted for separately; or (2) an exemption from the NRC allowing use of co-mingled funds for those purposes 6
Need for Exemption
- NRC regulations limit withdrawal from the DCPP NDTs to
$37.2M and limit spending to planning activities for radiological decommissioning
- The $37.2M is far less than the $187.8M ($2017) PG&E has estimated for pre-shutdown planning across all categories of decommissioning
- Planning activities include:
- Detailed executable work plans
- If PG&E delays decommissioning planning until after permanent cessation of operations, the overall cost of decommissioning would increase by nearly $166.1M ($2017). 7
Submittal Overview Request
- PG&E to withdraw a total of $187.8M ($2017) from the DCPP NDTs to fund decommissioning planning activities (radiological decommissioning, spent fuel management, and site restoration) necessary to support direct transition to decommissioning upon permanent cessation of operations
- Request NRC exemption approval by June 2019.
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Submittal Overview Justification
- Will Not Present an Undue Risk to Public Health and Safety
- Consistent with the Common Defense and Security
- If PG&E delays decommissioning planning until after permanent cessation of operations, the overall cost of decommissioning would increase by nearly $166.1M ($2017). Therefore, compliance with the rule would result in an undue hardship.
- Withdrawal of $187.8M ($2017) for pre-shutdown planning will not impact the ability to complete radiological decommissioning (~$2.6B) with existing NDT amounts. Therefore, application of the rule is not necessary to achieve the underlying purpose of the rule.
- Environmental Consideration 9
Additional Basis in Exemption Request
- Estimate of pre-shutdown planning costs by year
- Economic analysis demonstrating the increased cost to PG&E customers due to delayed decommissioning planning
- Reduced cost of security, operations, fire protection, and overall decommissioning project staffing during active decommissioning
- Allows for a prompt transition to decommissioning status
- Decommissioning cash flows for DCPP Units 1 and 2
- Demonstrates $187.8M ($2017) in pre-shutdown planning will not impact the ability to complete radiological decommissioning
(~$2.6B) with existing NDT amounts
Summary
- PG&E currently intends to promptly enter DECON after expiration of the current DCPP Units 1 and 2 operating licenses in November 2024 and August 2025, respectively
- Exemption from 10 CFR 50.82(a)(8)(ii) and 10 CFR 50.82(a)(8)(i)(A) is requested to allow PG&E to withdraw a total of $187.8M ($2017) from the DCPP NDTs to fund decommissioning planning activities prior to cessation of operations for radiological decommissioning, spent fuel management, and site restoration (NRC approval requested by June 2019). Disbursement requests from the trust will be made in nominal dollars for the year they are disbursed.
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Summary
- Conducting decommissioning planning before cessation of operations will result in an overall decommissioning cost savings of $166.1M ($2017)
- It is in every stakeholders interest for the DCPP NDTs to be effectively utilized
- The public interest in prompt and efficient DCPP decommissioning weighs in favor of using NDT funds to perform the work now to expedite decommissioning later
- Withdrawal of $187.8M ($2017) for planning activities will not impact the ability to complete radiological decommissioning.
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